Gutierrez v. Astrue

Filing 9

ORDER by Magistrate Judge Maria-Elena James granting 8 Stipulation (rmm2S, COURT STAFF) (Filed on 8/1/2012)

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1 2 3 Geri N. Kahn, Esq., SBN 148536 400 Montgomery Street, Suite 810 San Francisco, CA 94104 Tel. (415) 397-5446 Fax (707) 361-0350 Email: gkahn@pacbell.net 4 5 UNITED STATES DISTRICT COURT 6 NORTHERN DISTRICT OF CALIFORNIA 7 SAN FRANCISCO DIVISION 8 9 10 Candida GUTIERREZ, 11 Plaintiff, 12 vs. 13 MICHALE J. ASTRUE, Commissioner of 14 Social Security, 15 Defendant. 16 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 3:12-cv-01390-MEJ STIPULATION TO EXTEND DUE DATE OF PLAINTIFF’S BRIEF IN SUPPORT OF HER MOTION FOR SUMMARY JUDGMENT; AND [PROPOSED ORDER] 17 Plaintiff, by and through her attorney of record, and Defendant, by and through 18 his attorney of record, hereby stipulate, subject to the approval of the Court, to a 60-day 19 extension of time for Plaintiff’s counsel to file a brief in support of her Motion for 20 Summary Judgment, in light of the following: 21 1. Plaintiff’s counsel is a sole practitioner and has other matters with 22 approaching deadlines. The transcript in this proceeding is over 500 23 pages. Plaintiff’s counsel needs additional time to review the transcript 24 and to write the Motion. 25 Stipulation of Extension of Time to File S/J, 3:12-cv-01390 MEJ - 1 1 2. Plaintiff’s counsel has spoken with Theophous Reagans, Esq., 2 defendant’s counsel and he has indicated that he is agreeable to a 60 day 3 extension of time for counsel to prepare her brief. 4 3. Should the request be granted, Plaintiff’s brief will be due on October 1, 5 2012, Defendant’s reply brief on October 31, 2012 and Plaintiff’s optional 6 response brief on November 14, 2012. 7 Respectfully submitted, 8 Dated: July 31, 2012 /s/ Geri N. Kahn GERI N. KAHN Attorney for Plaintiff Dated: July 31, 2012 /s/ Theophous Reagans THEOPHOUS REAGANS Special Assistant United States Attorney Attorney for Defendant 9 10 11 12 13 14 15 16 ORDER Pursuant to stipulation, IT IS SO ORDERED. 17 18 19 1 Date: August ___, 2012 Maria-Elena James United States Magistrate Judge 20 21 22 23 24 25 Stipulation of Extension of Time to File S/J, 3:12-cv-01390 MEJ - 2

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